FILED FOR RECORD

CAUSE NO. _____________

DAVID MEISELL, et al.
Plaintiffs,
V.
ECTOR COUNTY HOSPITAL DISTRICT,
WILLIAM WEBSTER, DAVID NELSON,
MARY E. THOMPSON, JUDY HAYES,
DAVID DUNN, VIRGIL TROWER,
RICHARD HERRERA, and
MARY LOU ANDERSON,
Defendants.

Cause No.: B-16-12-1180-CV

Ector County - 161st District Court
Ector County, Texas
12/19/2016 2:43:11 PM
Clarissa Webster
District Clerk
By: Natalie Guthrie, Deputy

IN THE DISTRICT COURT OF

ECTOR COUNTY, TEXAS

___TH JUDICIAL DISTRICT

PLAINTIFFS ORIGINAL PETITION

AND REQUEST FOR TEMPORARY RESTRAINING ORDER,
TEMPORARY INJUNCTION, AND PERMANENT INJUNCTION
Plaintiffs, David H. Meisell and numerous others listed for convenience in Exhibit A hereto,
file this Original Petition and Request for Temporary Restraining Order, Temporary Injunction,
and Permanent Injunction against Defendants, Ector County Hospital District, William Webster,
David Nelson, Mary E. Thompson, Judy Hayes, David Dunn, Virgil W. Trower, and Mary Lou
Anderson (collectively Defendants).
A.
1.

DISCOVERY CONTROL PLAN

Plaintiffs intend to conduct discovery under Level 3 of Texas Rules of Civil

Procedure 190.4 because Plaintiffs request immediate injunctive relief.

B.
2.

PARTIES

Most of the 176 Plaintiffs are retirees from the Medical Center Hospital (the

Hospital) in Ector County, Texas, who are eligible for and have earned retirement benefits that
the Defendants have threatened to deny to the Plaintiffs after January 1, 2017. The remainder of

the Plaintiffs are current employees hired before January 1, 1993, and are or will become eligible
for retirement benefits.
3.

Defendant Ector County Hospital District is a quasi-governmental entity authorized

by the State of Texas. It can be served by serving its Secretary Virginia Sredanovich at her usual
place of business, the Medical Center Hospital in Odessa, Texas.
4.

Defendant William Webster is the Hospitals Chief Executive Officer responsible

for the day to day operations of the Hospital and the administration of the Employee Retirement
Plan and Group Medical Plan. He can be served at his usual place of business, the Medical Center
Hospital in Odessa, Texas.
5.

Defendant David Nelson is a member of the Board of Directors of the Ector County

Hospital (the Board) that wrongfully terminated Plaintiffs earned retirement benefits. He
resides at 7022 Robbie Road, Odessa, Texas 79765, where he can be served with process.
6.

Defendant Mary E. Thompson is a member of the Board that wrongfully terminated

Plaintiffs earned retirement benefits. She resides at 1106 Douglas, Odessa, Texas 79762, where
she can be served with process.
7.

Defendant Judy Hayes is a member of the Board that wrongfully terminated

Plaintiffs earned retirement benefits. She resides at 1802 W. Crescent, Odessa, Texas 79761,
where she can be served with process.
8.

Defendant David Dunn is a member of the Board that wrongfully terminated

Plaintiffs earned retirement benefits. He resides at 1501 Ridgecrest Avenue, Odessa, Texas
79763, where he can be served with process.

9.

Defendant Virgil Trower is a member of the Board that wrongfully terminated

Plaintiffs earned retirement benefits. He resides at 52 Sunny Grove, Odessa, Texas 79762, where
he can be served with process.
10.

Defendant Richard Herrera is a member of the Board that wrongfully terminated

Plaintiffs earned retirement benefits. He resides at 1515 Golder, Odessa, Texas 79762, where he
can be served with process.
11.

Defendant Mary Lou Anderson is a member of the Board that wrongfully

terminated Plaintiffs earned retirement benefits. She resides at 2012 W. 15th Street, Odessa, Texas
79763, where she can be served with process.
C.
12.

FACT ALLEGATIONS

Ector County established Medical Center Hospital as a non-profit hospital that first

opened its doors in December, 1949. The Ector County Commissioners appointed a Board of
Directors to govern the Hospital. The Board hired the Hospital Administrator who ran the day to
day operations of the Hospital.
13.

In 1990, the Texas legislature authorized the creation of the Ector County Hospital

District. Since that time a seven member Board of Directors elected directly by the citizens of
Ector County governs the Hospital and otherwise functions in much the same manner as when the
Hospital was county-owned. The Board hires the Administrator (renamed the Chief Executive
Officer) who runs the day to day operations with the help of several staff officers.
14.

Today the Hospital has approximately 2,000 employees. In order to hire and retain

its employees, the Hospital has from its earliest days offered a package of wages and benefits,
including retirement, pension and health benefits. When it was county-owned, the Hospital
employees contributed to a state retirement fund in lieu of social security taxes. Other County

employees contributed to both. Hospital employees, unlike other County employees, are therefore
not eligible for social security. For at least some of its history, the Hospital opted out of Medicare
taxes, which meant some employees were not eligible for Medicare.
15.

To provide health benefits for retiring employees the Hospital offered, as part of

the retirement package for employees who met eligibility requirements based on years of service,
a health insurance benefit. That benefit promised retirees continued participation for life in the
Employee Health Benefit Plan as if they were regular employees and at no premium cost for the
retiree. Retirees, like regular employees, could add dependents with the payment of an additional
premium. The Plaintiff retirees except for current Hospital employees have completed their
eligibility requirements, retired and thereby earned the right to participate in the Group Health
Plan.
16.

The retirement health benefit plan was available to eligible retirees since at least

the early 1980s and perhaps years earlier. The brochure distributed to employees, effective
February 1, 1981, states: Retirees will be included [in the Employee Health Benefit Plan] for
coverage on the same basis as Employees. A summary statement of benefits distributed around
the same time states: Free medical insurance to retirees upon retirement.
17.

The Employee Handbook distributed to employees effective April 1, 1981, states:

Retirees of the Texas County and District Retirement System and the Hospital will receive the
Employee Health Plan free to them. (Emphasis added.)
18.

In 1992 the Board voted to end the retirement health insurance benefit for persons

hired after January 1, 1993, but the benefit continued as promised for those hired before that date.
The retirement plan has been consistently administered pursuant to the terms described above with
minor modifications for no less than 35 years until October of this year.

19.

In October, 2016, the Board announced that it was terminating the retirees and

their dependents participation in the Employee Health Benefit Plan, as of January 1, 2017. For
some retirees, the Board offered to replace the retirement health insurance benefit described
above with a health reimbursement arrangement (HRA).
20.

The HRA is not a suitable replacement for participation in the Group Medical Plan

for at least the following reasons: (1) the Board has made no representation about benefits beyond
2017; (2) the HRA makes no provisions for dependents; (3) in many cases the retiree cannot obtain
equivalent coverage for the amounts allocated to the HRA; (4) retirees no longer in the Hospitals
Group Medical Plan are subject to market risks for the cost and availability of coverage; (5) the
retirees may not be able to retain their current doctors through the HRA and 6) the absence of
COBRA and other benefits available to regular employees.
21.

The Boards action adversely affects each of the 175 Plaintiffs (and their

dependents) and approximately 125 additional retirees (and their dependents) receiving benefits
or eligible to receive benefits. In addition, there are 88 known current employees who are or will
become eligible for the health insurance retirement benefit upon retirement because they were
hired prior to January 1, 1993. In sum, there are approximately 400 potential claimants.
22.

In one instance William Webster, the Hospitals Chief Executive Officer, signed a

written agreement with Plaintiff Freda Daniels, dated May 5, 2015, that stated the Plaintiff will
also then {upon retirement} be eligible for retiree health insurance, since she was hired before
January 1, 1993.
23.

Plaintiffs counsel gave notice to the Defendants of its claims and requested a

special Board session to discuss those claims. Defendants have denied the Plaintiffs request for
a hearing to discuss their actions.

24.

Exhibits B and C are the affidavits of J. Michael Stephans, retired Administrator of

the Hospital, and David H Meisell, former Director of Human Resources. Each affidavit supports
the allegations made above.
D.
25.

COUNT 1 BREACH OF CONTRACT

Plaintiffs incorporate by reference the foregoing allegations in Paragraphs 1-23 of

this Petition.
26.

Plaintiffs are parties to a valid and binding contract with Ector County Hospital by

which Plaintiffs, upon completion of eligibility requirements based on years of service, are entitled
to certain benefits in exchange for their services as Hospital employees. Specifically, the contract
provides that eligible employees would be allowed, upon their retirement, to continue participating
for life in the Employee Health Benefit Plan on the same basis as regular employees and at no
premium cost to them. In particular, the retirees would, like regular employees, be able to add
dependents to their health plans with the payment of an additional premium.
27.

The Hospitals promise of continued lifetime participation in the Employee Health

Benefit Plan after retirement was a benefit that was offered to each Plaintiff as an incentive to work
for the Hospital, and was part of the mutual agreement into which Plaintiffs entered with the
Hospital when they accepted and continued employment there. All of the Plaintiffs accepted this
offer at the time they accepted employment with the Hospital, and further indicated their
acceptance by their continued employment and provision of services for the Hospital over the
course of many years.
28.

The Hospitals promise of continued lifetime participation in the Employee Health

Benefit Plan for eligible retirees is reflected in writing in various summary plan descriptions and
other documents, including without limitation: (1) the health plan brochure distributed to

employees, effective February 1, 1981, which states: Retirees will be included [in the Employee
Benefit Plan] for coverage on the same basis as Employees, (2) the summary statement of
benefits, which states: Free medical insurance to retirees upon retirement, and (3) the Employee
Handbook distributed to employees effective April 1, 1981, which states: Retirees of the Texas
County and District Retirement System and the Hospital will receive the Employee Health Plan
free to them. (Emphasis added.)
29.

The Hospitals promise of continued lifetime participation in its Employee Health

Benefit Plan for eligible retirees was a material term of the mutual agreement by which Plaintiffs
agreed to work for the Hospital.
30.

Plaintiffs satisfied and fully performed their obligations, in that they maintained

their employment and provided services to the Hospital in accordance with the duties and
responsibilities of their respective positions with the Hospital, and satisfied the length-of-service
requirement and any other eligibility requirements for the retirement health benefits they had been
contractually promised namely, continued participation for life in the Employee Health Benefit
Plan on the same basis as regular employees at no premium cost, and with the ability to add
dependents to their health plans with the payment of an additional premium.
31.

Any other conditions precedent under the contract between Plaintiffs and

Defendants have been satisfied.

32.

Defendants have materially breached or anticipatorily breached this contract by

announcing and voting to terminate Plaintiffs and their dependents participation in the Employee
Health Benefit Plan, as of January 1, 2017.
33.

For some retirees, the Hospitals Board has offered to replace the retirement

health insurance benefit with a HRA, but the HRA is not a suitable replacement for participation

in the Group Medical Plan for at least the following reasons: (1) the Board has made no
representation about benefits beyond 2017; (2) the HRA makes no provisions for dependents; (3)
in many cases the retiree cannot obtain equivalent coverage for the amounts allocated to the HRA;
(4) retirees no longer in the Hospitals Group Medical Plan are subject to market risks for the cost
and availability of coverage; (5) the retirees may not be able to retain their current doctors through
the HRA; and 6) the absence of COBRA and other benefits available to regular employees. The
offer to replace the retirement health insurance benefit with a HRA therefore does not cure
Defendants material breach of contract.
34.

In addition, on May 5, 2015, Defendant William Webster executed a separate

written contract on behalf of the Hospital with Plaintiff Freda Daniels in connection with her
retirement from the Hospital. That contract specified that Plaintiff Freda Daniels will also then
be eligible for retiree health insurance, since she was hired before January 1, 1993.
35.

Plaintiff Fred Daniels has satisfied and fully performed her obligations pursuant to

the May 5, 2015 contract, and any other conditions precedent to the contract between Plaintiff
Freda Daniels and the Hospital have been satisfied.
36.

Defendants termination of the retirement health insurance benefit for Plaintiff

Freda Daniels therefore constitutes a separate material breach of the Hospitals May 5, 2015
contract with her.
37.

Defendants material breaches have caused injury to Plaintiffs, which have resulted,

or will result in damages to Plaintiffs. Because of Defendants material breaches, Plaintiffs now
must procure replacement health insurance for themselves and their dependents. The replacement
health insurance options available to Plaintiffs (whether through the HRA option offered to some
Plaintiffs, or through the private insurance market) either require Plaintiffs and their dependents

to pay more than they would have paid for the Hospitals retirement health insurance benefit, or
fail to offer the same scope of coverage, or some combination of both. Thus, Plaintiffs are forced
to pay more for less coverage, and also will be forced to incur additional out-of-pocket costs to
obtain health care services under their replacement insurance. For at least some Plaintiffs, the
costs associated with procuring replacement health insurance will be prohibitive.
E.
38.

COUNT 2 PROMISSORY ESTOPPEL

Plaintiffs incorporate by reference the foregoing allegations in Paragraphs 1-36 of

this Petition.
39.

In the alternative to Count 1, Defendants have breached promises to Plaintiffs upon

which Plaintiffs reasonably and substantially relied, and their breaches will cause injury, damages,
and injustice to Plaintiffs if the promises are not enforced.
40.

As an enticement and incentive to hire and retain employees, Defendants promised

Plaintiffs as part of their retirement that upon completion of certain eligibility requirements based
on years of service, Plaintiffs would be allowed, upon their retirement, to continue participating
for life in the Employee Health Benefit Plan on the same basis as regular employees at no premium
cost, and would be able to add dependents to their health plans with the payment of an additional
premium.
41.

Plaintiffs relied on Defendants promises by choosing to work for the Hospital, and

by maintaining their employment with the Hospital, sometimes at below-market wages, for
sufficient years to become eligible for the retirement health benefit, thus foregoing other
employment options or opportunities during their periods of employment for the Hospital. Given
the nature of Defendants promises, Plaintiffs reliance on those promises was both reasonable and
substantial.

42.

Defendants knew or should have known that Plaintiffs individually relied on

Defendants promises.
43.

Defendants have now breached their promises, upon which Plaintiffs reasonably

and substantially relied, by terminating the lifetime retirement health insurance benefit as of
January 1, 2017.
44.

Defendants breach of their promises has caused, is causing, and will cause injury

to Plaintiffs, who now must procure replacement health insurance for themselves and their
dependents. The replacement health insurance options available to Plaintiffs (whether through the
HRA option offered to some Plaintiffs, or through the private insurance market) either require
Plaintiffs to pay more than they would have paid for the Hospitals retirement health insurance
benefit, or fail to offer the same scope of coverage, or some combination of both. Thus, Plaintiffs
are forced to pay more for less coverage, and also will be forced to incur additional out-of-pocket
costs to obtain health care services under their replacement insurance. For at least some Plaintiffs,
the costs associated with procuring replacement health insurance will be prohibitive.
45.

Injustice to Plaintiffs can only be avoided if Defendants promises are enforced.

F.

46.

EQUITABLE RELIEF

Plaintiffs incorporate by reference the foregoing allegations in Paragraphs 1-44 of

this Petition.
47.

Request for Temporary Restraining Order

48.

Plaintiffs injunction request is only that the Court continue the status quo that has

been in effect for at least thirty-five years.

10

49.

Plaintiffs application for a temporary restraining order is authorized by Tex. Civ.

Prac. & Rem. Code 65.011.

50.

Plaintiffs ask this Court to enter an Order to preserve the status quo by directing

Defendants to honor their promises and contractual obligations to Plaintiffs and to continue the
retirement health insurance benefits to which Plaintiffs are entitled namely, Plaintiffs
entitlement to continue participating for life in the Employee Health Benefit Plan on the same basis
as regular employees and at no premium cost to the retiree for his coverage, and other benefits,
including the ability to add dependents to their health plans with the payment of an additional
premium for the duration of their participation.
51.

Plaintiffs are likely to succeed on the merits of their claim and to recover from

Defendants after a trial on the merits because:

(a)

Plaintiffs will demonstrate: (i) the existence of a contractual agreement

between Plaintiffs and Defendants, by which Defendants promised to provide the lifetime
retirement health insurance benefits described above to Plaintiffs if Plaintiffs accepted
employment with the Hospital and satisfied the eligibility criteria based on years of service;
(ii) Plaintiffs performance and satisfaction of all obligations, conditions, and eligibility
criteria necessary for them to receive the benefit; (iii) Defendants breach of the contractual
agreement by terminating the promised lifetime retirement health insurance benefits; and
(iv) damages to Plaintiffs; or
(b)

In the alternative, Plaintiffs will demonstrate: (i) that as an enticement and

incentive to hire and retain employees, Defendants promised Plaintiffs that upon
satisfaction of the eligibility requirements based on years of service, Plaintiffs would be
allowed, upon their retirement, to continue participating for life in the Employee Health

11

Benefit Plan at no premium cost, and would be able to add dependents to their health plans
with the payment of an additional premium; (ii) Plaintiffs relied on Defendants promises,
and Plaintiffs reliance was reasonable and substantial; (iii) Defendants knew, or should
have known that Plaintiffs would rely on their promises; (iv) Defendants breached their
promises by terminating the promised lifetime retirement health insurance benefits; and (v)
Plaintiffs will suffer damages and injustice if Defendants promises are not enforced.
52.

If Plaintiffs request for a temporary restraining order is not granted, they will suffer

imminent harm because their retirement health insurance benefits will terminate as of January 1,
2017. They will be forced to search for replacement health insurance, which likely will cost more
and provide less coverage; indeed, for at least some Plaintiffs, the costs will be prohibitive and
they will not be able to obtain insurance. For others who may be able to afford replacement health
insurance, the costs of any such insurance will require depletion of savings and cause financial
hardship. For some Plaintiffs there is an immediate need for medical services, including surgery,
and they do not know the status of insurance coverage which may cause them to forego needed
medical treatment.
53.

The imminent harm to Plaintiffs if a temporary restraining order is not issued is

irreparable because Plaintiffs will be forced to go forward with either less health insurance
coverage than they had under the Employee Health Benefit Plan or no health insurance at all,
subjecting Plaintiffs to the risk of crippling financial costs (and possibly bankruptcy) if they require
substantial health care services. The risk here is particularly acute because Plaintiffs are retirees
who are mostly elderly, many of whom (or whose dependents, who are covered under the
Employee Health Benefit Plan) have persistent health conditions that require regular and costly

12

treatment that they will not be able to obtain because they cannot procure suitable and equivalent
replacement insurance.
54.

The imminent harm to Plaintiffs is also irreparable because even for Plaintiffs who

may be able to procure replacement insurance, they will be subject to higher costs and will not
receive equivalent coverage, and thus will suffer significant financial hardship as a result of the
termination of the retirement health insurance benefits that the Hospital promised them.
55.

Plaintiffs have no adequate remedy at law because in the absence of a temporary

restraining order, their retirement health insurance benefits from the Hospital will terminate as of
January 1, 2017. Plaintiffs therefore would lose their promised health insurance benefits, and
would be forced to incur all of the accompanying financial and health-related hardships, during
the pendency of this action, if not for longer. No remedy at law could compel the continuation of
the retirement health insurance benefits to which Plaintiffs are entitled, nor would Plaintiffs be
able to obtain suitable and equivalent replacement health insurance at the same cost. Only
injunctive relief can maintain the status quo and prevent the harms that Plaintiffs would suffer due
to the loss of their promised retirement health insurance benefits.
56.

Counsel for the Board has indicated the Board may claim sovereign immunity and

claim that the Hospital is immune from legal remedies.

57.

Plaintiffs are willing to post a reasonable bond.

Request for Temporary Injunction

58.

For the reasons set forth above, Plaintiffs also request a temporary injunction to

preserve the status quo and maintain their promised retirement health insurance benefits during
the pendency of this action.

13

59.

Plaintiffs request that the Court set their application for a temporary injunction for

a hearing and, after the hearing, issue a temporary injunction directing Defendants to honor their
promises and contractual obligations to Plaintiffs and to continue the retirement health insurance
benefits to which Plaintiffs are entitled namely, Plaintiffs entitlement to continue participating
for life in the Employee Health Benefit Plan on the same basis as regular employees and at no
premium cost for the retiree coverage, and other benefits, including the ability to add dependents
to their health plans with the payment of an additional premium for the duration of their
participation.
60.

Plaintiffs have joined all indispensable parties under Texas Rule of Civil

Procedure 39.
Request for Permanent Injunction
61.

For the reasons set forth above, Plaintiffs also request a permanent injunction.

62.

Plaintiffs request that the Court set their request for a permanent injunction for a

trial on the merits and, after the trial, issue a permanent injunction directing Defendants to honor
their promises and contractual obligations to Plaintiffs and to continue the retirement health
insurance benefits to which Plaintiffs are entitled namely, Plaintiffs entitlement to continue
participating for life in the Employee Health Benefit Plan on the same basis as regular employees
and at no premium cost for the retiree, and other benefits, including the ability to add dependents
to their health plans with the payment of an additional premium for the duration of their
participation.
G.
63.

JURY DEMAND

Plaintiffs demand a jury trial and tender the fee with this petition.

14

H.
64.

CONDITIONS PRECEDENT

All conditions precedent to Plaintiffs claims for relief have occurred, or have

been performed or satisfied.

I.
65.

REQUEST FOR DISCLOSURE

Plaintiffs request pursuant to Texas Rule of Civil Procedure 194 that Defendants

disclose, within 50 days of the service of this request, or such shorter period as the Court orders,
the information and material described in Rule 194.2.
J.
66.

PRAYER

Plaintiffs ask that the Court issue citation for the Defendants to appear and answer,

and that Plaintiffs be awarded judgment for the following:

a.

A temporary restraining order to preserve the status quo and prevent Plaintiffs

promised retirement health insurance benefits from terminating on January 1, 2017;

b.

A temporary injunction to preserve the status quo and maintain Plaintiffs promised

retirement health insurance benefits for at least the pendency of this action;
c.

A permanent injunction directing Defendants to honor their promises and

contractual obligations to Plaintiffs and to continue the retirement health insurance benefits to
which Plaintiffs are entitled namely, Plaintiffs entitlement to continue participating for life in
the Employee Health Benefit Plan on the same basis as regular employees and at no premium cost
for the retirees coverage, and other benefits, including the ability to add dependents to their health
plans with the payment of an additional premium for the duration of their participation;
d.

Actual damages, including (but not limited to) any consequential damages incurred

as a result of Defendants actions;

e.

Pre-judgment and post-judgment interest;

15

f.

Court costs;

g.

Reasonable and necessary attorneys fees; and

h.

All other relief to which Plaintiffs may be entitled.

Respectfully submitted,
MCGUIREWOODS, LLP

/s/ Jacks C. Nickens

Jacks C. Nickens
State Bar No. 15013800
600 Travis Street, Suite 7500
Houston, Texas 77002
Telephone: (713) 353-6668
Facsimile: (832) 214-9931
Email: jnickens@mcguirewoods.com
ATTORNEYS FOR PLAINTIFFS

85152331_1.docx

16

EXHIBIT A

EXHIBIT A
CLAIMANTS

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.

CLAIMAINTS
Aguirre, Connie and Manuel
Alvarado, Gloria
Alvarez, Maria C.
Anderson, Barbara S.
Anderson, Ronalyn Denise
Baker, Daniel Polk and Diana Jean
Baker, Randy
Barrera, Olga
Bee, Jean Ann
Bersosa, Janileah
Bevacqua, Lucretia
Bickham, Susan
Bivins, Janhee and Terry Paul
Blackwood, Bettye
Blaydes, Sandra
Brown, Sue A.
Browne, Elsa and Otho
Byerly, Shelley
Carillo, Manuela N.
Cardenas, Martha
Canlas, Cristina Hernando and Med Layug
Carter, Johnnie
Caskey, Cathy
Cates, Carol T.
Chance, Catherine
Chancy, Yvette
Channell, Patsy R.
Cheng, Fausto S.
Chou, Yuchih
Christopher, Johnna
Cockrell, Linda
Cooper, Linda
Corrales, Juan
Corrales, Maria Corazon
Cree, Julie
Cuba, Rosetta
Daniel, Jose
Daniels, Freda
Davis, Debra F.
De Duenas, Petronila A.
dela Rosa, Angelita

42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
83.
84.
85.
86.

DeShazo, Leona
Dominguez, Olga
Dominguez, Yolanda F.
Douglas, Mary Elizabeth
Drager, Linda
Durham, John
Figert, Ruth
Fletcher, Suzanne
Folgrave, Kenneth
Ford, Hope and Steve
Fuentes, Benjamin
Galindo, Julia G.
Gifford, Brenda
Gilbert, Martha
Glanton, Tammy
Gold, Belinda and Tim
Gonzalez, Carlos H.
Graham, Diane
Green, Quanah
Grissom, Johnny and Janet
Guerrero, Dora
Guyton, Rachel
Haenelt, Wanda
Ham, Linda Kay
Hefflin, Corinne
Hefflin, Roy
Hetzler, Jeff
Hill, Barry Turner and Linda Diane
Hinojos, Yolanda
Ivison, Susan
Johnson, Darlene
Johnson, Rebecca G.
Jones, Annamarie
Jones, Donna
Jones, Patricia
Kelly, Gale Ares
Kendall, Louise
Kepple, John
Kimberlin, Patti N.
Koenig, Kay
Kull, Mary
LaRoque, Linda N.
Lay, Barbara
Leasure, Vicky
Lloyd, Sharon L.

87.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
99.
100.
101.
102.
103.
104.
105.
106.
107.
108.
109.
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112.
113.
114.
115.
116.
117.
118.
119.
120.
121.
122.
123.
124.
125.
126.
127.
128.
129.
130.
131.

Longoria, Diana
Lopez, Maria
Lyons, Beverly
Mancha, Leonarda C.
Mathes, Marilyn
Martin, Brenda D.
Martinez, Alphonso V.
Martinez, Lorina
Martinez, Pedro R.
McDaniel, Kathy and Steve
McDaniel, Kimberly
McKown, Sandra L.
McPherson, Deborah and Billy
Meador, Debra
Meek, Marilyn S.
Molinar, Alicia
Morales, Beatrice
Morolez, Juan
Morris, Deborah
Moses, Wanda (Jeannie)
Nelson, Margaret
ODaniel, Robert Earl
Oliva, Rene and Dalila
Olivas, Joanne
Oracion, Minda and Renato
Ordner, Ann D.
Ornelas, Dianna
Padilla, Norma
Pantoja, Garaciela
Parsons, Beverly
Pearce, Roma Charlene
Pelopero, Edna L.
Pena, Maria D. and Humberto
Pineda, Raquel V.
Pokky, Eric
Pornan, Barbara
Pornan, Jr., Mariano
Porter, Tina
Press, Donna
Press, Theodore Allen
Pruett, Helen
Ramirez, Carla A.
Rainey, Rex G. and Debra L.
Renfro, Sherry
Rodriguez, Julie & Gilberto

132.
133.
134.
135.
136.
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161.
162.
163.
164.
165.
166.
167.
168.
169.
170.
171.
172.
173.
174.
175.

Rolls, Barbara S.
Ross, Marva L.
Rowan, Lisa D.
Ruiz, SanJuana
Russell, John R. and Carla D.
Ruvalgaba, Ricardo R.
Salmon, Jose and Manuela
Sanchez, Delfina
Sanchez, Frances and Efrain
Sanderlin, Mary
Samp, Cecilia
Seely, Betty and James
Severance, Rebecca K. and Glen
Sifuentez, Graciela
Skalenda, Kendra R. and Kevin A.
Skidmore, Paula
Solomon, Phylis
Souther, Tara
Springer, Cynthia
Springer, Donna
Stephans, John M.
Subia, Isaac
Taylor, Vicki
Thomas, Vickey L.
Thompson, Theodora R.
Tijerina, Linda
Uhlhorn, Lisa and Billy
Urias, Alicia
Uy, Anita
Vaughn, Gwendolyn C.
Walker, Letha Pearl
Wang, Lin Hong
Watson, Nettie Laura
Weaver, Margaret
White, Louise and Robert
Wright, Bobby D. Jr. and Candelaria B.
Wright, Candace
Wright, Glenda
Wright, Gloria
Wright, Sherry Ann
Yancey, Rebecca L.
Yandrich, John Michael
Young, Teri
Zuniga, Anastacio

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EXHIBIT B

EXHIBIT C